First, [Microsoft] included IE with Windows and required OEMs not to delete it. Second, it designed IE and Windows in such a way that it was difficult for anyone, OEMs or end users to delete it. The legality of Microsoft's contractual and technological linking of the browser and the operating system arose first in the interpretation of the 1995 consent decree and then in the 1998 case in the application of sections 1 and 2 of the Sherman Act. The issue in the consent decree case was whether the browser and the operating system were integrated, and therefore specifically exempt from the decree's anti-tying provisions. The Sherman Act section I issue was whether the browser was illegally tied to Windows, either contractually or by design. The Sherman Act section 2 issue was whether the technological and contractual linking of the browser and the operating system constituted illegal maintenance of a monopoly in operating systems. (...)

In his findings of fact, Judge Jackson treated Microsoft's contractual and technological bundling of IE and Windows as a single strategy to constrict the OEM channel. He first found that browsers are separate from operating systems. Consumers think of the browser as simply software that allows them to gain access to information on the Web. Some consumers want the browser provided separately from the operating system, either because they want a browser other than IE or because they do not use a browser and do not want one taking up space on the hard drive. Other operating system producers bundle a browser with their operating systems but they allow OEMs and users to delete it. Microsoft prohibits deletion even though it offers different versions of its browser separately for non-Windows operating systems.

Instead of integrating its own browser in Chrome OS, Google will build the operating system as an extension of the browser. In less than 10 years, browsers have evolved from being one of the many applications that can be installed on a computer to being an essential application that could even be used to replace a traditional operating system.